Disclosure Requirements - Croatia

16.06.2011

Disclosure Category: 3

Background and legal basis

The basis for the disclosure obligation, which falls on the shareholder, derives from the Securities Market Law of 2 July 2002.

It is, however, our understanding that the Croatian Financial Services Supervisory Agency (HANFA) and the Croatian National Bank have the right to request disclosure of shareholder information from Erste Bank’s depository Erste & Steiermärkische Bank in Croatia. In such a case, the holding of CBL’s depository Erste Bank would be disclosed to the requesting authorities.

Obligation to report threshold crossings

Any direct or indirect acquisition or disposal by a natural or legal person that causes a holding to reach, exceed or fall below 10%, 20%, 25%, 50% or 75% of the total will require such person to send a written notice to HANFA and to the issuer about each such acquisition or disposal without delay and at the latest within four days after the transaction.

Sanctions

Any legal person who does not supply information about ownership pursuant to Article 115 of the Securities Market Law shall be subject to a fine of between HRK 60,000 and HRK 1 million. Natural persons who do not fulfil such obligation shall be subject to a fine of between HRK 20,000 and HRK 200,000.